Description

A mixed invoice (or complex single operation) under Article 257 ter II of the CGI has multiple elements that are so closely linked they form a single indivisible economic provision. One operation is the principal, and the other is accessory to it. The accessory operation follows the VAT regime (category, timing) of the principal operation.

This affects both e-invoicing (B2B) and e-reporting (B2C). For e-reporting, the seller must determine the category of the principal operation (goods delivery or service provision) and apply it to all associated operations for Flux 10.3/10.4 transmission. For e-invoicing, the standard invoice flow applies, but the buyer's deductible VAT timing follows the principal operation category.

When operations are genuinely independent (not accessory), each operation maintains its own VAT category and timing. The seller must determine the economic substance of the transaction to classify it correctly.

Key characteristics

• Principal operation determines VAT category for all accessory operations (Art. 257 ter CGI).

• Accessory = elements so closely linked they form a single indivisible economic provision.

• B2B: Standard e-invoicing; VAT timing follows principal operation.

• B2C e-reporting: Principal operation category used for all operations in Flux 10.3/10.4.

• Independent operations (not accessory): each has its own category and VAT timing.

• Seller determines principal vs. accessory based on economic substance.

Relationship to other use cases

Use case 31 is a clarification use case affecting how invoices with multiple operation types are treated. It does not introduce new invoice flows but modifies how existing flows (standard e-invoicing and e-reporting) handle multi-category transactions. Use case 16 is related in that it involves mixing VAT categories (O + others), while use case 31 addresses the economic relationship between operations.

Business and tax context

Legal and regulatory framework

Article 257 ter II of the CGI defines the single complex operation principle. The determination of principal vs. accessory is based on the perspective of the average consumer and the economic substance of the transaction. The accessory follows the principal's VAT rules in all respects (rate, timing, territorial rules).

Common business scenarios

Software + installation

Software (goods) is principal; installation (service) is accessory.

Hotel + breakfast

Accommodation (service) is principal; breakfast (goods) is accessory.

Machine + maintenance contract

Machine (goods) is principal; maintenance (service)is accessory.

Catering with delivery

Food (goods) is principal; delivery (service) is accessory.

Tax and accounting implications

For VAT timing: if the principal is goods (VAT on delivery), all operations follow delivery timing. If the principal is services (VAT on receipt unless debit option), all operations follow receipt timing. This affects when Encaissée must be sent and the buyer's VAT deduction timing.

Key data requirements

No more data fields are needed beyond standard invoice fields. The seller determines the principal operation category and applies it consistently across all operations in the invoice and in e-reporting.

Implementation considerations

Seller considerations

• Determine principal vs. accessory operation for each complex transaction.

• Apply principal operation category consistently in invoice and e-reporting.

• VAT timing (and therefore Encaissée obligation) follows the principal operation.

Buyer considerations

• VAT deduction timing follows the principal operation of the invoice.

General considerations

• Systems must support mixed operation classification and correct VAT timing determination.

SCI mapping

Standard SCI mappings apply. No mixed-invoice SCI fields exist; the classification is managed through BT-8 (VAT exigibility) and BT-23 (billing framework).